37.0 Graphic Arts Systems 

(2010 revision, draft 1) 

11129/1994 xxlxxI2010 

37.1	 Applicability 

37.1.1	 The provisions of 37.0 of this regulation apply to any packaging rotogravure, publication 

rotogravure, or flexographic printing press at any facility whose maximum theoretical 

emissions of volatile organic compounds (YOCs) (including solvents used to clean each 

of these printing presses) without control devices from all printing presses are greater 

than or equal to 7.7 tons per year, on and after [insert effective date of this regulation], 

and 

37.1.2	 Transition period for existing permitted sources. Every owner or operator of press that is 

subject to 37.5.1.2.2 of this regulation and that is covered by a permit issued pursuant to 

7 DE Admin Code 1102 or 1130 containing all applicable conditions of 37.0 of this 

regulation, as that regulation existed on November 29. 1994, shall comply with those 

permit conditions until December 31 2010. On and after January 1. 2011. every such 

owner or operator of any flexible package printing facility shall comply with the provisions 

of 37.0 of this regulation. 

37.1.~ An owner or operator of a facility whose emissions are below the applicability threshold§. 

in 37.1.1 and 37.5.1.2.2 of this regulation shall comply with the certification, 

recordkeeping, and reporting requirements of 37.7.1 of this regulation. 

37.1.9 Any facility that becomes or is currently subject to the provisions of 37.0 of this regulation 

by exceeding the applicability threshold§. in 37.1.1 and 37.5.1.2.2 of this regulation will 

remain subject to these provisions even if its emissions later fall below the applicability 

threshold§.. 

37.1.Q4 Any facility that is currently sUbject to a state or federal rule promulgated pursuant to the 

Clean Air Act Amendments of 1977 by exceeding an applicability threshold is and will 

remain subject to these provisions, even if its throughput or emissions have fallen or later 

fall below the applicability threshold. 

37.2	 Definitions. As used in 37.0 of this regulation, all terms not defined herein shall have the 

meaning given them in the November 15, 1990 Clean Air Act Amendments, or in 2.0 of this 

regulation. 

"Add-on air pollution control device (APeD)" means an emission control device or system 

that is originally separated from an emission source but can be later added or installed to the 

emission source to reduce emission from the source. 

"Flexible packaaing" means any package or part of a package the shape of which can be 

readily changed. Flexible packaging includes. but is not limited to. bags. DOuches, liners. and 

wraps utilizing paper. plastic film alumjnum foil. metalized or coated paper or film, or any 

combination of these materials. 

"Flexible packaging printing" means printing, coating and laminating activities being performed 

on or in-line with a flexible packaging printing press. 
"Flexographlc printing press" means a printing press that uses a roll printing technique in 

which the pattern to be applied is raised above the printing roll and the image carrier is made 

of rubber or other elastomeric materials. 

"Packaging rotogravure printing press" means a rotogravure printing press used to print on 

paper, paper board, metal foil, plastic film, and other substrates that are, in sUbsequent 

operations, formed into packaging products and labels, and other non-publication products. 

"Press-Ready Ink" means ink, as applied \0 a substrate, aller all solvents and diluents have 

been added. 

"Prinllng press" means equipment used to apply words, pictures, or graphic designs to either a 

continuous substrate or a sheet. A continuous substrate consists of paper, plastic, or other 

material that is unwound from a roll, passed through coating or ink applicators and any 

associated drying areas. The press includes all coating and ink applicators and drying areas 

between unwind and rewind of the continuous substrate. A sheet consists of paper, plastic, or 

other material that is carried through the process on a moving belt. The press includes all 

coating and ink applicators and drying operations between the time that the sheet is put on 

the moving belt until it is taken off. 

"Publication rotogravure printing press" means a rotogravure printing press on which the 

following paper products are printed: 

1.	 Catalogues, including mail order and premium. 

2.	 Direct mail advertisements, including circulars, letters, pamphlets, cards, and printed 

envelopes. 

3.	 Display advertisements, including general posters, outdoor advertisements, car cards, 

Window posters; counter and floor displays; points-of-purchase, and other printed display 

material. 

4.	 Magazines, books. 

5.	 Miscellaneous advertisements, including brochures, pamphlets, catalogue sheets, 

circular folders, announcements, package inserts, book jackets, market circulars 

magazine inserts, and shopping news. 

6.	 Newspapers, magaZine and comic supplements for newspapers, and preprinted 

newspaper inserts, including hi-Ii and spectacolor rolls and Sections. 

7.	 Periodicals. 

8.	 Telephone and other directories, including business reference services. 

"Roll printing" means the application of words, designs, and pictures to a substrate, usually by 

means of a series of rolls each with only partial coverage. 

"Rotogravure printing press" means any printing press designed to print on a substrate using a 

gravure cylinder. 

37.3 Standards 

37.3.1 No owner or operator of a packaging rotogravure or flexographic printing press subject to 

37.0 of this regUlation shall apply any coating or ink unless the vac content is equal to or 

less than one of the follOWing: 
37.3.1.1	 40% vae by volume of the coating or ink, excluding water and exempt 

compounds, as applied. 

37.3.1.2	 25% vae by volume of the volatile content in the coating or ink, as applied. 

37.3.1.3	 0.5 kilogram (kg) vae per kg (0.5 pound [Ib] vae per Ib) coating solids, as 

applied. 

37.3.2	 No owner or operator of a publication rotogravure printing press subject to 37.0 of this 

regulation shall apply any coating or ink unless the vae content is equal to or less than 

one of the following: 

37.3.2.1	 40% vac by volume of the coating or ink, excluding water and exempt 

compounds, as applied. 

37.3.2.2	 25% vae by volume of the volatile content in the coating or ink, as applied. 

37.3.3	 As an alternative to compliance with the limits in 37.3.1 or 37.3.2 of this regulation, an 

owner or operator of a packaging rotogravure, publication rotogravure, or flexographic 

printing press may comply with the requirements of this regulation by meeting the 

requirements of 37.4 or 37.5 of this regulation. 

37.4	 Daily-weighted average limitations 

37.4.1	 No owner or operator of a packaging rotogravure, publication rotogravure, or flexographic 

printing press shall apply, during any day, coatings or inks on the subject printing press 

unless the daily-weighted average, by volume, vac content of all coatings and inks, as 

applied, each day on the subject printing press is equal to or less than the limitation 

specified in either 37.3.1.1 or 37.3.2.1 (as determined by 37.4.4); 37.3.1.2 or 37.3.2.2 (as 

determined by 37.4.5); or, in the case of packaging rotogravure or flexographic printing, 

37.31.3 (as determined by 37.4.6) of this regulation. 

37.4.2	 An owner or operator may comply with the daily-weighted average limitation by grouping 

coatings or inks used on a printing press into two categories that meet the conditions in 

37.4.2.1 and 37.4.2.2 of this regUlation. Any use of averaging between the two categories 

of coating or inks used on a packaging rotogravure press or on a flexographic press 

requires compliance with the emission standard in 37.3.1.3 of this regulation, as 

determined by the equation in 37.4.6 of this regulation. 

37.4.2.1	 The daily-weighted average vac content for the first category shall comply with 

37.3.1.1 or 37.3.2.1 of this regulation, as determined by applying the equation in 

37.4.4 of this regulation to the coatings or inks in this first category. 

37.4.2.2	 The daily weighted-average vae content for the second category shall comply 

with 37.3.1.2 or 37.3.2.2 of this regulation, as determined by applying the 

equation in 37.4.5 of this regulation to the coatings or inks in this second 

category. 

37.4.3	 Compliance with 37.0 of this regulation shall be demonstrated through the applicable 

coating or ink analysis test methods and procedures specified in Appendix B of this 

regulation and the recordkeeping and reporting requirements specified in 37.7.3 of this 

regulation. 
37.4.4	 The following equation shall be used to determine if the weighted average VaG content 

of all coatings and inks, as applied, each day on the subject printing press exceeds the 

limitation specified in 37.3.1.1 or 37.3.2.1 ofthis regulation: 

iL,V""", 

VOCtOXAj := " t.,1 x 100 

LL,(V. + v""",) h'l 

(37-1) 

where:
 

VaG(')(A) =The weighted average VaG content in units of percent VaG by volume of all
 

coatings and inks (excluding water and exempt compounds) used each day. 

i = Subscript denoting a specific coating or ink, as applied. 

n = The number of different coatings or inks, as applied, each day on a printing press. 

L, =The liquid volume of each coating or ink, as applied, used that day in units of liters (L) 

(gallons [gal]). 

V. = The volume fraction of solids in each coating or ink, as applied.
 

Vvoc, =The volume fraction of VaG in each coating or ink, as applied.
 

37.4.5	 The following equation shall be used to determine if the weighted average VaG content 

of all coatings and inks, as applied, each day on the sUbject printing press exceeds the 

limitation specified in 37.3.1.2 or 37.3.2.2 of this regulation: 

fL,V""", 

VOC~~I= x100 

LL,tv",,)

,-, 

(37-2) 

where:
 

VaGI')IB) =The weighted average VaG content in units of percent VaG by volume of the
 

volatile content of all coatings and inks used each day. 

i =Subscript denoting a specific coating or ink, as applied. 

n = The number of different coatings or inks, as applied, each day on each printing press. 

L, =The liquid volume of each coating or ink, as applied, in units of L (gal). 

Vvoc, =The volume fraction of VaG in each coating or ink, as applied. 

Vvc' =The volume fraction of volatile matter in each coating or ink, as applied. 

37.4.6	 The following equation shall be used to determine if the weighted average VaG content 

of all coatings and inks, as applied, each day on the subject printing press exceeds the 

limitation specified in 37.3.1.3 of this regulation: 

, 

LL,D,W""", 

VOC(illCl =~-­

LL,D,W. 

1,1 

(37-3) 
where:
 

vac'i)(cl ; The weighted average vac content in units of mass of vac per mass of
 

coating solids. 

i ; Subscript denoting a specific coating or ink, as applied. 

n ; The number of different coatings or inks, as applied, each day on a printing press. 

L, ; The liquid volume of each coating or ink, as applied, used on the day in units 

of L (gal). 

D; ; The density of each, as applied, in units of mass of coating or ink per unit 

volume of coating or ink. 

Wvoc; ; The weight fraction of voe in each coating or ink, as applied. 

W,; =The weight fraction of solids in each coating or ink, as applied. 

37.5	 Control devices 

37.5.1	 No owner or operator of a packaging rotogravure, publication rotogravure, or flexographic 

printing press equipped with a control system shall operate the printing press unless the 

owner or operator meets one of the requirements under 37.5.1.1 and 37.5.1.2 of this 

regulation. 

37.5.1.1	 Control device efficiency 

37.5.1.1.1	 A carbon adsorption control device is used that reduces the voe emissions 

delivered from the capture system to the control device by at least 90% by 

weight. 

37.5.1.1.2	 An incineration control device is used to reduce voe emissions delivered 

from the capture system to the control device by at least 90%, by weight. 

37.5.1.1.3	 Any other voe emission control device is used to reduce the voe emissions 

delivered from the capture system to the control device by at least 90%. 

37.5.1.2	 Overall control efficiency. The printing press is equipped with a capture system 

and control device that provides aA g'/eFall emissigA red~sligA eflisieAsy gf at 

lea6l: 

37.5.1.2.1	 For any press not subject to 37.5.1.2.2 of this regulation, an overall emission 

reduction efficiency of at least: 

37.5.1.2.1,.1 75% for a publication rotogravure printing press. 

37.5.1.2.1,.2 65% for a packaging rotogravure printing press. 

37.5.1.2.1,.3 60% for a flexographic printing press. 

37.5.1.2.2	 For any individual flexible packing printing press with the potential-te-emit 

before controls greater than 25 tons of vae oar year an overall emission 

reduction efficiency specified in 37.5.1.2.1. or specified in 37.5.1.2.2.1 

through 37.5.1.2.2.4 below. whichever is higher: 
37.5.1.2.2.1	 80% for any press that was first installed on or after March 14. 

1995 and that is controlled by an APCD whose first installation 

date was on or after (insert the effective date of this revision). 

37.5.1.2.2.2	 75% for any press that was first installed on or after March 14. 

1995 and that is controlled by an APCD whose first installation 

date was prior to (insert the effective date of this revision). 

37.5.1.2.2.3	 70% for any press that was first installed prior to March 14. 1995 

and that is controlled by an APCD whose first installation date was 

on or after linsert the effective date of this revision). 

37.5.1.2.2.4	 65% for any press that was first installed prior to March 14.1995 

and that is controlled by an APCD whose first installation date was 

prior to linsert the effective date of this revision). 

37.5.2	 An owner or operator of a packaging rotogravure, publication rotogravure, or f1exographic 

printing press equipped with a control system shall ensure thaI: 

37.5.2.1	 A capture system and control device are operated at all times that the printing 

press is in operation, and the owner or operator demonstrates compliance with 

37.0 of this regulation through the applicable coating analysis and capture 

system and control device efficiency test methods specified in Appendix B, 

Appendix D and Appendix E of this regulation and in accordance with the 

capture efficiency test methods in Appendix D of this regulation. 

37.5.2.2	 The control device is equipped with the applicable monitoring equipment 

specified in 2.0 of Appendix D of this regulation, and the monitoring equipment 

is installed, calibrated, operated, and maintained according to the vendor's 

specifications at all times the control device is in use. 

37.6	 Test methods. The vac content of each coating and ink and the efficiency of each capture 

system and control device shall be determined by the applicable test methods and 

procedures specified in Appendix A through Appendix D of this regulation to establish the 

records required under 37.7 of this regUlation. 

37.7	 Recordkeeping and reporting 

37.7.1	 Requirements for exempt sources. Within six months after finsert the effective date of this 

revision of 37.01 By NevemBer 15, 199J, any owner or operator of a printing press that is 

exempt from the requirements of 37.0 of this regulation because of the criteria in 37.1 of 

this regulation shall comply with the following: 

37.7.1.1	 Initial certification. The owner or operator shall certify to the Department that the 

facility is exempt under the provisions of 37.1 of this regulation. Such certification 

shall include: 

37.7.1.1.1	 The name and location of the facility. 

37.7.1.1.2	 The address and telephone number of the person responsible for the facility. 
37.7.1.1.3	 A declaration that the facility is exempt from 37.0 of this regulation because 

of the criteria in 37.1 of this regulation. 

37.7.1.1.4	 Calculations demonstrating that total potential emissions of vac from all 

flexographic and rotogravure printing presses at the facility are and will be 

less than 7.7 tons per year of press-ready ink, before the application of 

capture systems and control devices. Total potential emissions of vac for a 

flexographic or rotogravure printing facility is the sum of potential emissions 

of vac from each flexographic and rotogravure printing press at the facility. 

The following equation shall be used to calculate total potential emissions of 

vac per calendar year before the application of capture systems and control 

devices for each flexographic and rotogravure printing press at the facility: 

(37-4) 

where: 

Ep =Total potential emissions of vac from one flexographic or rotogravure printing 

press in units of kilograms per year (kg/yr) (pounds per year [Ib/ yr]). 

A =Weight of vac per volume of solids of the coating or ink with the highest vac 

content, as applied, each year on the printing press in units of kilograms VOC per 

liter (kg VaC/L) (pounds of vac per gallon lib VaC/gal]) of coating or ink solids. 

B =Total volume of solids for all coatings and inks that can potentially be applied 

each year on the printing press in units of liters per year (Uyr) (gallons per year 

[gallyr]). The instrument or method by which the owner or operator accurately 

measured or calculated the volume of coating and ink solids applied and the 

amount that can potentially be applied each year on the printing press shall be 

described in the certification to the Department. 

37.7.1.2	 Recordkeeping. The owner or operator shall collect and record all of the following 

information each year for each printing press and maintain the information at the 

facility for a period of five years: 

37.7.1.2.1	 The name and identification number of each coating and ink, as applied, 

each year on each printing press. 

37.7.1.2.2	 The weight of vac per volume of coating solids and the volume of solids of 

each coating and ink, as applied, each year on each printing press. 

37.7.1.2.3	 The total potential emissions as calculated in 37.7.1.1.4 of this regulation 

using vac content for that year. 

37.7.1.3	 Reporting. Any record showing that total potential emissions of vac from all 

printing presses exceed 7.7 tons per year of press-ready ink in any calendar year 

before the application of capture systems and control devices shall be reported 

by sending a copy of such record to the Department within 45 calendar days after 

the exceedance occurs. This requirement is in addition to any other State of 

Delaware exceedance reporting requirements. 

37.7.2	 Requirements for sources using complying coatings or inks. Any owner or operator of a 

printing press subject to 37.0 of this regulation and complying by means of use of 

complying coatings or inks, shall comply with the following: 
37.7.2.1	 Initial certification. \/VIthin six months after linsert the effective date of this revision 

of 37.01 By N9\l91l'111er 15, 1993, or upon initial startup of a new printing press, or 

upon changing the method of compliance for an existing SUbject printing press 

from daily-weighted averaging or control devices to use of complying coatings or 

inks, the owner or operator of a subject printing press shall certify to the 

Department that the printing press will be in compliance with 37.3.1 or 37.3.2 of 

this regulation on and after !insert the effective date of this revision of 37.01 

~'9vell'111er 15, 1993, or on and after the initial startup date. Such certification 

shall include: 

37.7.2.1.1	 The name and location of the facility. 

37.7.2.1.2	 The address and telephone number of the person responsible for the facility. 

37.7.2.1.3	 Identification of SUbject sources. 

37.7.2.1.4	 The name and identification number of each coating and ink, as applied. 

37.7.2.1.5	 The voe content of all coatings and inks, as applied. 

37.7.2.2	 Recordkeeping. On and after [insert the effective date of this revision of 37.01 By 

N9'/ell'111er 15, 1993, or on and after the initial startup date, the owner or operator 

of a printing press subject to the limitations of 37.0 of this regUlation and 

complying by means of 37.3.1.1 or 37.3.2.1 of this regulation shall collect and 

record all of the following information each day for each printing press and 

maintain the information at the facility for a period of five years 

37.7.2.2.1	 The name and identification number of each coating and ink, as applied. 

37.7.2.2.2	 The voe content of each coating and ink, as applied, expressed in units 

necessary to determine compliance. 

37.7.2.3	 Reporting. 

37.7.2.3.1	 Any record showing an exceedance of the voe contents of 37.3.1 or 37.3.2 

of this regulation shall be reported by the owner or operator of the subject 

printing press to the Department within 45 calendar days following the 

exceedance, in addition to complying with any other applicable reporting 

requirements. 

37.7.2.3.2	 At least 30 calendar days before changing the method of compliance with 

37.0 of this regulation from the use of complying coatings to daily-weighted 

averaging or control devices, the owner or operator shall comply with all 

requirements of 37.7.3.1 or 37.7.4.1 of this regUlation, respectively, as well 

as the requirements of 7 DE Admin. Code 1102. Upon changing the method 

of compliance with 37.0 of this regulation from the use of complying coatings 

to daily-weighted averaging or control devices, the owner or operator shall 

comply with all reqUirements of 37.7.3 or 37.7.4 of this regulation, 

respectively. 
37.7.3	 Requirements for sources using daily-weighted averaging. Any owner or operator of a 

printing press subject to the limitations of 37.0 of this regulation and complying by means 

of daily-weighted averaging shall comply with the following: 

37.7.3.1	 Initial certification. Within six months after [insert the effective date of this revision 

of 37.01 8y Nevemller 15. 1993, or upon initial startup of a new printing press, or 

upon changing the method of compliance for an existing subject press from use 

of complying coating or control devices to daily-weighted averaging, the owner or 

operator of the subject printing press shall certify to the Department that the 

printing press will be in compliance with 37.4 of this regulation on and after !insert 

the effective date of this revision of 37.01 Ne'Jemller 15, 1993, or on and after the 

initial startup date. Such certification shall include: 

37.7.3.1.1	 The name and location of the facility. 

37.7.3.1.2	 The address and telephone number of the person responsible for the facility. 

37.7.3.1.3	 The name and identification of each printing press that will comply by means 

of 37.4 of this regulation. 

37.7.3.1.5	 The name and identification number of each coating and ink available for use 

on each printing press. 

37.7.3.1.6	 The voe content of each coating and ink, as applied, each day on each 

printing press, expressed in units necessary to determine compliance. 

37.7.3.1.7	 The instrument or method by which the owner or operator will accurately 

measure or calculate the volume of each coating and ink, as applied, each 

day on each printing press. 

37.7.3.1.8	 The method by which the owner or operator will create and maintain records 

each day as required in 37.7.3.2 ofthis regulation. 

37.7.3.1.9	 An example of the format in which the records required in 37.7.3.2 of this 

regulation will be kepI. 

37.7.3.2	 Recordkeeping. On and after [insert the effective date of this revision of 37.01 

N9"emller 15, 1993, or on and after the initial startup date, the owner or operator 

of a printing press subject to the limitations of 37.0 of this regulation and 

complying by means of daily-weighted averaging shall collect and record all of 

the following information each day for each printing press and maintain the 

information at the facility for a period of five years: 

37.7.3.2.1	 The name and identification number of each coating and ink, as applied, on 

each printing press. 

37.7.3.2.2	 The voe content and the volume of each coating and ink, as applied, each 

day on each printing press, expressed in units necessary to determine 

compliance. 
37.7.3.2.3	 The daily-weighted average VOC content of all coatings and inks, as applied, 

on each printing press. 

37.7.3.3	 Reporting. On and after [insert the effective date of this revision of 37.OJ 

NQvember 15,1993, the owner or operator of a subject printing press shall notify 

the Department in the following instances: 

37.7.3.3.1	 Any record showing noncompliance with 37.4 of this regulation shall be 

reported by sending a copy of such record to the Department within 45 

calendar days following the occurrence. This requirement is in addition to any 

other State of Delaware exceedance reporting requirements. 

37.7.3.3.2	 At least 30 calendar days before changing the method of compliance with 

37.0 of this regulation from daily-weighted averaging to use of complying 

coatings or control devices, the owner or operator shall comply with all 

requirements of this regulation, respectively, as well as 7 DE Admin. Code 

1102. Upon changing the method of compliance with 37.0 of this regulation 

from daily-weighted averaging to use of complying coatings or control 

devices, the owner or operator shall comply with all requirements of 37.7.2 or 

37.7.4 of this regulation, respectively. 

37.7.4	 Requirements for sources using control devices. Any owner or operator of a printing 

press subject to 37.0 of this regulation and complying by means of control devices shall 

comply with 4.5 of this regulation and the following: 

37.7.4.1	 Initial certification. Within six months after [insert the effective date of this revision 

of 37.01 By ~IQ'Jember 15, 1993, or upon initial startup of a new printing press, or 

upon changing the method of compliance for an existing printing press from use 

of complying coatings or daily-weighted averaging to control devices, the owner 

or operator of the SUbject printing press shall perform all tests and submit to the 

Department the results of all tests and calculations necessary to demonstrate 

that the SUbject printing press will be in compliance with 37.5 of this regUlation, 

on and after [insert the effective date of this revision of 37.01 NQvember 15, 1993, 

or on and after the initial startup date. 

37.7.4.2	 Recordkeeping. On and after [insert the effective date of this revision of 37.01 

NQ>Jember 15, 1993, or on and after the initial startup date, the owner or operator 

of a printing press subject to the limitations of 37.0 of this regulation and 

complying by means of control devices shall collect and record all of the following 

information each day for each printing press and maintain the information at the 

facility for a period of five years: 

37.7.4.2.1	 Control device monitoring data. 

37.7.4.2.2	 A log of operating time for the capture system, control deVice, monitoring 

equipment and the associated printing press. 

37.7.4.2.3	 A maintenance log for the capture system, control device, and monitoring 

equipment detailing all routine and non-routine maintenance performed 

including dates and duration of any outages. 
37.7.4.3	 Reporting. On and after [insert the effective date of this revision of 37.01 

Na'Ia...ller 15, 1993, the owner or operator of a subject printing press shall notify 

the Department in the following instances: 

37.7.4.3.1	 Any record showing non-compliance with 37.5 of this regulation shall be 

reported by sending a copy of such record to the Department within 45 

calendar days following the occurrence. This requirement is in addition to any 

other State of Delaware exceedance reporting requirements. 

37.7.4.3.2	 At least 30 calendar days before changing the method of compliance with 

37.0 of this regulation from control devices to use of complying coatings or 

daily-weighted averaging, the owner or operator shall comply with all 

requirements of 37.7.2.1 or 37.7.3.1 of this regulation, respectively, as well 

as 7 DE Admin. Code 1102. Upon changing the method of compliance with 

37.0 of this regulation from control devices to use of complying coatings or 

daily-weighted averaging, the owner or operator shall comply with all 

reqUirements of 37.7.2 or 37.7.3 of this regulation, respectively.